Bench: Shri Mahavir Singh & Shri Manish Agarwal
270A of the Act respectively. 2. Since both the appeals are related to one assessee and against the additions made in reassessment order and consequent levy of penalty u/s 271A of the Act, therefore, they are taken together and ITA No. 236/DDN/2025 & 05/DDN/2026 decided by a common order. First we take assessee’s appeal in ITA No. 236/DDN/2025. ITA No.236/DDN/2025